Calvin E. Bartlett v. State of Tennessee, W2016-00616-CCA-R3-PC

Calvin E. Bartlett pled guilty in January 2015 to a package of reduced charges in two Madison County indictments; the plea called for concurrent sentences as a Range II offender producing an effective 10-year sentence; remaining charges were dismissed.
Bartlett filed a pro se post-conviction petition (later amended) alleging ineffective assistance of trial counsel and that his guilty pleas were unintelligent/involuntary.
At the evidentiary hearing Bartlett testified counsel failed to provide discovery, inadequately met with him, pressured him to plead in both cases, and did not argue mitigating factors for a lesser sentence.
Trial counsel testified he obtained/opened discovery (prosecutor had an open-file policy), reviewed it with Bartlett, discussed defenses and plea negotiations, and would have been prepared for trial.
The post-conviction court credited trial counsel’s testimony, denied relief, and Bartlett appealed; the Court of Criminal Appeals affirmed, finding no deficient performance or prejudice under Strickland and that the plea colloquy showed a knowing, voluntary plea.

Issue	Bartlett's Argument	State's Argument	Held
Counsel failed to object to classification as a Range II offender	Bartlett: counsel was ineffective for not challenging Range II status	State: parties may agree to offender classification in plea bargains; plea waived irregularity	Denied — no deficient performance shown and plea agreement was lawful when voluntarily entered
Counsel failed to provide complete discovery	Bartlett: he requested discovery and did not receive it, impairing his ability to prepare	State: prosecutor had open-file policy; counsel obtained/reviewed discovery with Bartlett	Denied — court credited counsel; no proof of deficient performance or prejudice
Counsel failed to adequately meet/consult with Bartlett	Bartlett: counsel did not meaningfully meet or prepare him, forcing plea	State: counsel met, discussed strategy and pleas; was prepared for trial	Denied — credibility resolved for counsel; no ineffective assistance proven
Ineffective assistance rendered guilty pleas unintelligent/involuntary	Bartlett: counsel’s alleged failures made pleas unknowing/coerced	State: plea colloquy and counsel’s assistance showed pleas were knowing, voluntary, and intelligent	Denied — petitioner failed to show Strickland prejudice or invalid plea; plea colloquy adequate

Momon v. State, 18 S.W.3d 152 (Tenn. 1999) (standard for reviewing post-conviction factual findings and plea challenges)
Fields v. State, 40 S.W.3d 450 (Tenn. 2001) (de novo review of post-conviction legal conclusions with presumption of factual findings)
Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (Strickland framework applied in Tennessee and deference to trial court credibility findings)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance: deficiency and prejudice)
Baxter v. Rose, 523 S.W.2d 930 (Tenn. 1975) (competence standard for counsel in Tennessee)
Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice standard for ineffective-assistance claims challenging guilty pleas)
Boykin v. Alabama, 395 U.S. 238 (1969) (plea must be knowing, voluntary, and intelligent)
Blankenship v. State, 858 S.W.2d 897 (Tenn. 1993) (factors for determining whether plea was voluntary and knowing)
Davis v. State, 313 S.W.3d 751 (Tenn. 2010) (parties may craft hybrid plea terms including offender classification so long as within statutory ranges)
Hoover v. State, 215 S.W.3d 776 (Tenn. 2007) (knowing and voluntary guilty plea waives irregularity in offender classification)